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importance of the activities performed at each business location,
and (2) the time spent at each place. Id. at 175.
Mrs. Popov practiced 4 to 5 hours per day in her home
office. Without practicing, she could not perform adequately and
risked losing employment. Thus, practicing at home was a very
important component to her success as a musician. In addition,
she used the home office to make demo tapes to further her
career. However, the Supreme Court stated: “We decide, however,
that the point where goods and services are delivered must be
given great weight in determining the place where the most
important functions are performed.” Id. In the instant case the
places where Mrs. Popov’s services are performed are the concert
halls and studios. Her performances in these places were what
earned her income. All the rest was preparatory to performing.
Therefore, while the home office where she prepared was an
important place for her business, we cannot say that it was her
principal place of business. Accordingly, she has not satisfied
the requirements of section 280A and is not entitled to a
deduction for the use of a home office.
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Last modified: May 25, 2011